A relevant person must develop and implement anti-money laundering (AML) policies, procedures, systems, and controls around periodic reporting to the relevant person’s senior management on the effectiveness of their AML and countering the financing of terrorism (CFT) program. The money laundering reporting officer (MLRO) must prepare and submit a periodic report to senior management capturing details about the effectiveness of the relevant person’s AML/CFT program, its implementation, relevant findings and recommendations.

This Practice Note elaborates on the MLRO’s responsibilities in ensuring the quality of the relevant person’s AML program and submitting reports to senior management regularly.

• AML: Anti-money laundering.

• Authorised person: Authorised firm or an authorised market institution.

• Authorised firm: An authorised person who holds a licence to carry on one or more financial services in or from the DIFC and is not an authorised market institution.

• Authorised market institution: An authorised person operating an exchange, a clearing house or an alternative trading system.

• Beneficial owner: A beneficial owner includes the following:

  • In relation to a customer, means a natural person who ultimately owns or controls the customer or a natural person on whose behalf a transaction is conducted, or a business relationship is established.